EPA Takes Historic Step to Revise Affordability Methodology

(September 16, 2020) – Thanks to years of tireless effort by NACWA, its members and the Association’s water sector partners, EPA has taken a major step toward overhauling its financial capability assessment methodology to better account for the impacts on economically disadvantaged communities. On September 15, the Agency released a pre-publication version of a Federal Register notice seeking comment on a Draft 2020 Financial Capability Assessment that, when finalized, the Agency says would effectively take the place of its existing 1997 guidance.

NACWA sent an Advocacy Alert to members earlier this week providing more information on EPA’s announcement and will provide a more detailed analysis of the proposal after we have a chance to fully review the expansive document. The Association also distributed a joint water sector press release  applauding EPA’s work and was quoted in EPA’s press release

NACWA has been working for nearly two decades to move EPA away from its sole reliance on median household income (MHI) as an indicator of affordability in the Clean Water Act context. NACWA’s most recent advocacy on this issue was based on a series of recommendations in a report developed jointly with the American Water Works Association (AWWA) and the Water Environment Federation (WEF), which was sent to EPA in early 2019.

The water sector report outlined new metrics for evaluating financial capability that could better account for impacts on low-income populations. Since that time, the water sector associations have been working in lockstep to engage EPA and encourage the agency to change its methodology. While EPA’s proposed approach continues to rely, in part, on its old metrics, key elements from the water sector report have been incorporated into EPA’s new draft document that directly influence the determination of financial burden based on impacts to low-income communities. 

NACWA is working together with AWWA and WEF to review the draft document in more detail and will be engaging the experts who developed the water sector report to provide a comprehensive review of EPA’s proposal.

Once published in the Federal Register, EPA is asking for public comments within 30 days. EPA staff are highly motivated to get this finalized before the end of 2020 and the water sector will be working quickly to get comments developed. Please send any feedback or comments to Chris Hornback.